Facility Access Controls: Contingency Operations-What to Do and How to Do It

In our series on the HIPAA Administrative Simplification Security Rule, this is the first implementation specification for the Physical Safeguard Standard, Facility Access Controls. This implementation specification is addressable. Remember, addressable does not mean “optional.” Rather, an addressable implementation specification means that a covered entity must use reasonable and appropriate measures to meet the standard. As we have noted in earlier postings on HIPAA.com, business associates of covered entities will be required to comply with the Security Rule safeguard standards, beginning February 17, 2010. This requirement is one of the HITECH Act provisions of the American Recovery and Reinvestment Act ARRA, signed by President Obama on February 17, 2009. What…

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Contingency Plan: Applications and Data Criticality Analysis-What to Do and How to Do It

In our series on the HIPAA Administrative Simplification Security Rule, this is the fifth implementation specification for the Administrative Safeguard Standard (Contingency Plan). This implementation specification is addressable.  Remember, addressable does not mean “optional.” Rather, an addressable implementation specification means that a covered entity must use reasonable and appropriate measures to meet the standard. As HIPAA.com has noted in earlier postings, with enactment of the American Recovery and Reinvestment Act of 2009 (ARRA) on February 17, 2009, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. What to Do Assess the relative criticality of specific applications and data in support of other…

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Contingency Plan: Testing and Revision Procedures-What to Do and How to Do It

In our series on the HIPAA Administrative Simplification Security Rule, this is the fourth implementation specification for the Administrative Safeguard Standard (Contingency Plan). This implementation specification is addressable. Remember, addressable does not mean “optional.” Rather, an addressable implementation specification means that a covered entity must use reasonable and appropriate measures to meet the standard. As HIPAA.com has noted in earlier postings, with enactment of the American Recovery and Reinvestment Act of 2009 (ARRA) on February 17, 2009, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. What to Do Implement procedures for periodic testing and revision of contingency plans. How to Do…

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Contingency Plan: Emergency Mode Operation Plan-What to Do and How to Do It

In our series on the HIPAA Administrative Simplification Security Rule, this is the third implementation specification for the Administrative Safeguard Standard (Contingency Plan). This implementation specification is required. As HIPAA.com has noted in earlier postings, with enactment of the American Recovery and Reinvestment Act of 2009 (ARRA) on February 17, 2009, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. What to Do Establish (and implement as needed) procedures to enable continuation of critical business processes for protection of the security of electronic protected health information while operating in the emergency mode. How to Do It Covered entities are required to develop…

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Contingency Plan: Disaster Recovery Plan-What to Do and How to Do It

In our series on the HIPAA Administrative Simplification Security Rule, this is the second implementation specification for the Administrative Safeguard Standard (Contingency Plan). This implementation specification is required. As HIPAA.com has noted in earlier postings, with enactment of the American Recovery and Reinvestment Act of 2009 (ARRA) on February 17, 2009, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. What to Do Establish (and implement as needed) procedures to restore any loss of data. How to Do It The content and procedures of a covered entity’s disaster recovery plan will be » Outcomes of the covered entity’s identification of vulnerabilities and…

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Contingency Plan: Data Backup-What to Do and How to Do It

In our series on the HIPAA Administrative Simplification Security Rule, this is the first implementation specification for the Administrative Safeguard Standard (Contingency Plan). This implementation specification is required. As HIPAA.com has noted in earlier postings, with enactment of the American Recovery and Reinvestment Act of 2009 (ARRA) on February 17, 2009, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. What to Do Establish and implement procedures to create and maintain retrievable exact copies of electronic protected health information. How to Do It Covered entities must backup electronic protected health information on a regular basis. When a computer system fails, it may…

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Contingency Plan: Sample Policy and Procedures

This is the seventh Administrative Safeguard Standard of the HIPAA Administrative Simplification Security Rule. It has five implementation specifications: Data backup plan; Disaster recovery plan; Emergency mode operation plan; Testing and revision procedures; and Applications and data criticality analysis. The first three are required; the last two are addressable. Addressable does not mean optional. Rather, an addressable implementation specification means that a covered entity must use reasonable and appropriate measures to meet the standard. Further, as HIPAA.com has noted earlier, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. HIPAA.com will outline What to do and How to do it for each…

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Contingency Plan-What This HIPAA Security Rule Administrative Safeguard Standard Means

This is the seventh Administrative Safeguard Standard of the HIPAA Administrative Simplification Security Rule.  It has five implementation specifications:  Data backup plan; Disaster recovery plan; Emergency mode operation plan; Testing and revision procedures; and Applications and data criticality analysis.  The first three are required; the last two are addressable.  Addressable does not mean optional.  Rather, an addressable implementation specification means that a covered entity must use reasonable and appropriate measures to meet the standard.  Further, as HIPAA.com has noted earlier, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. If a fire swept through a covered entity’s facility, the covered entity would…

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5010/D.0 Effective Date Tuesday, March 17, 2009; Compliance Date January 1, 2012

The version modification to the HIPAA Administrative Simplification transaction standards becomes effective Tuesday, March 17, 2009. Here are several critical things to know, drawn directly from the final rule published in the Federal Register on January 16, 2009. The final rule is available for download on the HIPAA.com site. Effective Date: The effective date [March 17, 2009] is the date that the policies set forth in this final rule take effect, and new policies are considered to be officially adopted. [74 Federal Register 3302] Compliance Date: On January 1, 2012, all covered entities will have reached Level 2 compliance, and must be fully compliant in using Versions 5010 and D.0…

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